FAA Publishes Bonderite AMOC
On Feb. 5, the FAA published an approved alternative method of compliance (AMOC) allowing the use of the renamed Henkel “Bonderite” products for all airworthiness directives and previously-approved AMOCs specifically calling for the application of “Alodine.”
Henkel changed the product’s name from “Alodine” to “Bonderite” as part of a “branding strategy” begun in 2014. In identifying the product, as seen on the safety data sheet for Bonderite M-CR 1201 AERO, the company continues to note “known as Alodine.” For clarity, the Henkel website includes a statement regarding the new branding: “There will be no changes to the product’s chemical formulation…[or] specifications…All approvals and certifications will remain valid.”
However, since the former brand name was specifically called out in ADs and previous AMOCs, the FAA issued an additional AMOC to remove any doubt that the switch was legitimate. When contacted regarding the matter, ARSA did not believe the additional government step was necessary, but assisted the agency in assuring the new publication provided a clear path to compliance for users of the chromate conversion product.
“The FAA should learn from this,” said ARSA Executive Director Sarah MacLeod. “When it calls out specific materials in a law, such as an airworthiness directive, a simple marketing change made by a company producing those materials can require bureaucratic backflips. This [new AMOC] is a fine fix, but the government needs to be more circumspect in proscriptive rulemaking.”
For the industry’s sake, the need to develop this AMOC should underscore the importance of differentiating between the process – the chromate conversion coating – and a name-brand. Though “alodining” had become shorthand for process, it is in fact referring to a brand name. Just as the agency did in its rules, maintenance providers codified a product name into their “tribal knowledge” and only exacerbated the confusion caused by a company’s marketing efforts.